NSW Department of Planning, Industry and Environment
PO Box 2155
DANGAR NSW 2309
Email: cl.enquiries@crownland.nsw.gov.au

 

Dear Sir/Madam

SSP Crown Land: Draft State Strategic Plan for Crown land

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and has many members in surrounding New South Wales. Its members include professional scientists, landowners, land managers and interested members of the public.

FOG has had a long term interest in crown land, including travelling stock reserves, with conservation values in NSW. We provided comments on the Travelling Stock Reserves and the Crown Lands Review in 2013, the Crown Lands Legislation White Paper in 2014, the NSW Travelling Stock Reserves – Draft State Planning Framework 2016-2019 in 2015 and the NSW Travelling Stock Reserve Review in 2017.

From 1999, in partnership with Snowy Mountains Regional Council, FOG has been involved in the management of Old Cooma Common Grassland Reserve, using our volunteers and obtaining grants to employ professional weeders. More recently FOG successfully applied for a tender to manage Top Hut Travelling Stock Reserve and, in an informal partnership with others several others, other TSRs in the south east region. The primary purpose of our involvement is to manage these Crown lands for their biodiversity values. FOG is also involved in discussions with the NSW Biodiversity Conservation Trust about their interest in managing several TSRs and at least one Crown reserve for their biodiversity values.

Preparation & Consultation Process

The Draft Plan, section 1.1 (p9), indicates “This draft plan has been prepared through research and consultation, including engaging with stakeholders who operate public consultation. on or who are involved with Crown land…”. This raises several issues:

• In the interests of consistency with the first of the listed seven enabling initiatives in Section 4, i.e. to “Make more of our information available and transparent”, inclusion of which specific stakeholders were engaged with in the drafting process and how they were engaged with would give a sense of the representativeness of the process thus far.
• It would be helpful to have transparency around the weighting process that will be or is likely to be applied to the submissions of all stakeholders both individually and as aggregate interest groupings or sectors for analysis purposes.
• Again in the interests of being informative and transparent it would have been helpful to have included at least summary data for each Division (Western, Central, Eastern) of the various Crown land types, usages/values/benefits, and associated estimates of aggregate areas, and tenures/land parcel numbers. This would allow all stakeholders to obtain a sense of the significance of the various land Crown types, usages, values and benefits and to better inform discussion, selection, assessment and decision making around Strategic Plan Priorities and Outcomes.

Travelling Stock Reserves & Biodiversity Conservation Values

It is not clear whether this Plan is meant to encompass Travelling Stock Reserves (TSRs). There is mention of TSRs on page 43 but no other discussion of these important parcels of crown land. While there is now a separate Travelling Stock Reserves State-wide Plan of Management, this should at least be referred to in the Plan for Crown Land.

We are somewhat concerned about the statement on page 13 in section 2 that “The range of potential uses mean that there are often competing interests or aspirations for the use of Crown land. Where there are competing claims we aim to resolve them in a way that is fair, equitable and aligned with government priorities. This supports our commitment to manage the land to the greatest benefit to the community of NSW.” While there are legislative requirements that endeavour to protect threatened native flora and fauna species and endangered ecological communities, there are none that protect rare or declining species and ecological communities. Our experience is that retaining and maintaining the conservation values of the habitat of such species and ecological communities is often not seen as a priority and frequently loses out to commercial interests and government development and infrastructure priorities. This also does not take into account the importance to our native species and ecological communities of connectivity between areas of high conservation value. In this regard TSRs are important, but there will be other pieces of Crown land that play a role in habitat connectivity and should be retained for their biodiversity conservation value.

Priorities for Crown Land

In regard to using Crown lands for conservation of landscapes and species (section 3.3 page 42), it is alarming that the only discussion of how this might be done in section 3.3.3 Support and restore environmental values on Crown land (page 43) is via offsets. While acknowledging that maintaining conservation values on any site requires resources, FOG has concerns about relying on offset monies to do so. The reason is that an offset means that the conservation values on a site elsewhere are being destroyed, so at the time the offset is done there is a net loss of the relevant species or ecological community across the landscape. While some offsets do result in improvements to the offset area, many in the long term do not, leaving the net loss in the species or ecological community. For example, at the EIANZ National Biodiversity Offsets Conference, 26-28 Aug 2019, Dr Ascelin Gordon from RMIT presented modelling showing that, even if an offset site results in no net loss over 30 years, once considered at the landscape scale there is a net loss in conservation values. As well, offsets can be seen as an easier and cheaper way to go than restoration or similar. If biodiversity conservation is really a government priority as purported in the Draft Plan then surely in the public interest, not only of NSW residents but also the broader Australian population, dedicated ongoing core government funding should be an imperative rather than leaving it the vagaries of the market and the private sector which time and again has demonstrated that it cannot generally be relied upon to value and protect public goods and services.The Draft Plan should also contain ideas and projects that provide better protection for biodiverse Crown lands in the long term, e.g. incentive programs.

We recommend that generally more be said about the importance of Crown lands containing high quality threatened ecological communities and habitat for threatened species and suggest that one or two examples, such as we have referred to, be mentioned.

Yours sincerely

 

Geoff Robertson
President

10 August 2020